Monthly Archives: August 2018

Email

“Yahoo, Bucking Industry, Scans Emails for Data to Sell,” The Wall Street Journal, August 29, 2018 A1.  Unlike its competition, Verizon scans your Yahoo and AOL emails and shares the data with advertisers trying to sell you stuff.

This blog focuses in part on Compliance with law and company policy and procedures.  Does one need to comply with the practices of others in the industry, even where that is not required?  Do “market forces” act as part of the Governance structure?

We already know that Yahoo feels it owns the data you exchange over their platform.  But telling others what sites you’ve visited is a bit different than telling them what you may have been mentioned in your email.

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Filed under Access, Compliance, Compliance (General), Controls, Governance, Information, Ownership, Ownership, Privacy

Who exactly are your partners?

“U.S. Probes Microsoft on Bribery,” The Wall Street Journal, August 24, 2018 B1.  DOJ probes sales of software licenses to middlemen for ultimate sales to smaller governments.

Did the middlemen in, say, Hungary, share their discounted purchase price with government officials by way of bribes?  Even if they did, is Microsoft liable?  Unless the middlemen were Microsoft sales agents (who didn’t take title to the software licenses), or Microsoft knew of the scheme, hard to see FCPA liability for Microsoft.  Were the middlemen business partners of Microsoft, or just intermediate purchasers?

The ethics of the people with whom you do business can come back to bite you.  Your policies may apply by contract to consultants and third parties that you engage, but do they apply to the people to whom you sell/license your product?

 

 

 

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Filed under Compliance, Compliance (General), Controls, Corporation, Duty, Governance, Oversight, Policy, Third parties, Vendors

Finally, we have a winner

At least somebody goes to jail for leaking top secret information about Russian hacking of elections.  In less than a year and a half.

“Former Intelligence Contractor Gets Five Years in Prison for Leak,” The Wall Street Journal, August 24, 2018 A2. Reality Winner, a contract worker at the NSA, gets sentenced for leaking a secret report on election hacking by the Russians from the NSA to a news outlet.

The rules do need to be enforced from time to time, or they are more like guidelines.  And contractors seem to be a weak link.

Did anyone else in the chain of command get punished?  If she were in Washington, DC, rather than Augusta, Ga., would she have faced the same fate?

See also https://infogovnuggets.com/2017/06/06/we-have-a-winner/.

 

 

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Filed under Compliance, Compliance (General), Controls, Duty, Employees, Governance, Internal controls, Oversight, Protect assets, Third parties, Vendors

Who’s the boss?

To have governance, is a single point of accountability required?

“Workers Deal With Too Many Bosses,” The Wall Street Journal, August 21, 2018 B1.  According  to a recent poll, two-thirds of employees have more than one boss.  Some employees respond by trying to manage their bosses.

From a Governance perspective, if you have multiple bosses, who sets your priorities?  Who establishes the policies and procedures and instructions that you, as an employee, must follow?  How does one resolve conflicts?

And which one person in your organization bears responsibility/accountability for the overall Governance of your company’s Information?  Your company’s overall Compliance with law and with company policy and procedures?

Without such a single point of accountability/responsibility, who gets punished if things don’t go right?  If no one is held responsible/accountable at the C-suite level, do you really have a program-in-fact, as opposed to a program-on-paper?

 

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Filed under Compliance, Compliance (General), Controls, Corporation, Directors, Duty, Employees, Governance, Internal controls, Supervision, Who is in charge?

Labels

Labels are shorthand.  Does the person using the label mean the same thing as you do?

“For Some Bonds, It’s Too Easy Being Green,” The Wall Street Journal, August 20, 2018 B1.  A quarter of Chinese bonds marketed as green bonds were rejected by “a de facto watchdog for the market” as not really being environmentally friendly.

On the Internet, no one knows you’re a dog.  In the world of finance, who validates your dogness?  What does it say about a company that tells fibs about the greenness of their bonds?

Are labels inherently suspect?  Or inherently believable?

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Filed under Accuracy, Communications, Controls, Culture, Definition, Governance, Information, Internal controls, Third parties

Ownership

Appliances we use often capture data about how we use them.  Who owns that data, where is it stored, and what is it used for (and by whom)?

“What Your Car Knows About You,” The Wall Street Journal, August 18, 2018 B4. Large of amounts of data being collected from on-board devices, and used by car makers and others.

Will this lead to more targeted advertising?  May be worth $750 billion by 2030.  How much of that will the car owners get?

Sure, currently you have to opt in to this service.  You will read (and understand) the terms and conditions, won’t you?  And this will all be stored securely, with your privacy protected, won’t it?  Not that anyone could use your location or your driving habits against you.

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Filed under Access, Accuracy, Analytics, Controls, Information, Ownership, Privacy, Security, Technology, Value

Controlling speech

How does one control speech in the public forum without encroaching upon fundamental freedoms?

“On Social Media, a Battle Is Brewing Between Bots and Trolls,” The Wall Street Journal, August 11, 2018 B7. Blocking some speech and some speakers would be bad if the government did it.  But is it better if private companies do it, especially when they have pervasive power over the communications streams currently in use?

There’s battle brewing, indeed.  Are the Facebooks and Googles of the world mere utilities getting paid solely for carrying content from all comers, with no power (or financial interest?) over the content they carry, or are they publishers with some accountability?  If the technology tools they use to screen out the “bad” stuff (terrorists, for example) also screen out unpopular (to someone) speech, who pays damages?

If a company is quasi-governmental, shouldn’t it be subject to quasi-constitutional limitations?

This seems to me to be Governance, Compliance, and Information.

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Filed under Access, Accuracy, Communications, Compliance, Compliance (General), Controls, Corporation, Data quality, Duty, Governance, Government, Internal controls, Third parties